I realize that this is past the deadline for comments as per your public
notice, but this is an informal comment that does not pertain directly to
the issue at hand.  I am sure that this issue of universal service is an
important one, and I'd like to know what america thinks about it.
However, this would require a clear, straightforward presentation of the
issue at hand, which I do not see in your website, either from the page
where I found this e-mail address:
http://www.fcc.gov/Bureaus/Common_Carrier/Public_Notices/1998/da980002.html

Or from any of the informational pages about Universal Service (since
there are no links to these from the aforementioned page, this is just
whatever else I could find on your website)  Apparently the procedure for
commenting formally about this issue is as convoluted as the presentation
of the issue itself.  Since I was asked to quote directly, this is the
procedure I am talking about:

An original and four copies of all formal comments must be filed in
accordance with Section 1.51(c) of the Commission's Rules, 47 C.F.R. §
1.51(c). In addition, one copy of each pleading must be filed with
International Transcription Service, Inc. (ITS), the Commission's
duplicating contractor, at its office at 1231 20th Street, NW, Washington,
D.C. 20036, and one copy with Sheryl Todd, Federal Communications
Commission, Universal Service Branch, 8th Floor, 2100 M Street, NW,
Washington, D.C. 20554.

So I write an original, and make four copies.  And then I look up section
1.51(c) of the Commission's Rules (wherever that may be).  Okay.  Also I
send a copy to the duplicating contractor.  And then I send a copy to
Sheryl Todd.  So that's an original and six copies of a document, five of
them processed according to some rules you made reference to (but did not
post anywhere from this page, or tell me where I could find a copy) and
two other copies sent to different places.  And then, if I'm feeling
really enthusiastic...

Parties are also asked to submit copies of their formal comments on
diskette. Such diskette submissions are in addition to and not a
substitute for the formal filing requirements addressed above. Parties
submitting diskettes should submit them to Sheryl Todd, Federal
Communications Commission, Universal Service Branch, 8th Floor, 2100 M
Street, NW, Washington, D.C. 20554. Such a submission should be on a 3.5
inch diskette formatted in an IBM compatible form using WordPerfect 5.1
for Windows or compatible software. The diskette should be submitted in
"read only" mode.  The diskette should be clearly labelled with the
party's name, proceeding ("Report to Congress on Universal Service"), type
of pleading, and date of submission. Each diskette should contain only one
party's comments in a single electronic file, with a filename based on the
name of the party. The diskette should be accompanied by a cover letter.
All comments received on diskette will be made available for viewing on
the FCC World Wide Web site at .

Alright.  So I'd be requested to give you an electronic file.  How, I ask?
On a disk.  So instead of sending you, say, e-mail, or uploading a file,
I'm sending a disk through the US Mail.  Okay.  And a disk can hold, what,
well, in this case, a 3.5" diskette "formatted in an IBM compatible form"
probably will hold 1.4MB.  (Although, since the format wasn't specified,
it could be 1.7MB, or 720KB, or even 360KB)  And it should have the little
tab flipped to read only.  I can handle that.  I label the disk with four
items, probably about as much as will fit on the label.

But the disk itself should have one file on it (with its name based on
mine...).  The same file that I should have already sent a hard copy of to
seven places, including Sheryl Todd.  So she gets a printed copy, a disk,
and... a cover letter for a disk?  What do I need to say about it that
isn't on the label, on the disk, or--most obviously--already in the hard
copy?

So this file should be in an old version of WordPerfect compatible with
the Windows version?  Now, fortunately, my University has WordPerfect, but
this is version 6.0 for UNIX, and we can just hope that saving it in the
version 5.1 file format is compatible for WordPerfect 5.1 for Windows.

However, let's just assume for the sake of argument that I do all of this,
and it works.  What will you do with the disk?  Put it online on your web
site?  There must be an easier way to accomplish this than getting a disk
sent to you by US Mail.  I can see making this an option for people
without internet access, but wouldn't it be easier just to specify a
common format (like Rich Text, or even HTML since that is what it'll end
up as) and ask people to e-mail it, encoded if necessary, and have a
person deal with those (or just a dedicated computer if possible) instead
of having someone copying one file from however many individual disks and
then converting them?
 
Thank you for listening to my comments.  I only hope that one day
government documents will be accessible to the people that the government
ultimately answers to.  These long and complicated procedures waste your
time and mine, time that should be spent speaking about the issues for
which this time was originally allocated.  I am a computer programmer, and
if I made my programs this complicated I would probably only be employed
by a government agency, because no one in industry could possibly get away
with doing this and claiming that it is "productive".

Good luck,

Peter Baylies